ML20024C311

Responds to NRC 830526 Ltr Re Violations Noted in IE Insp Repts 50-352/83-05 & 50-353/83-02.Corrective Actions:Project QC Instruction E-2.0 Revised & Drawing FJ-44-18 Revised to Include Steel Barrier Per Section 10.0 of M-830

ML20024C311
Person / Time
Site:	Limerick
Issue date:	06/24/1983
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20024C306	List: ML20024C311
References
NUDOCS 8307120508
Download: ML20024C311 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 00 'IOOI PHILADELPHIA. PA.19101 JOHN 5. KEMPE R n nsnu a ms an ne e anue Mr. Thomas E. Murley, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

US NRC IE Letter, dated May 26, 1983 RE: Site Inspection of March 19 - April 22,1983 Inspection Report No. 50-352/83-05 and 50-353/83-02 Limerick Generating Station, Units 1 & 2 File: QUAL l-2-2 (352/83-05 and 353/83-02)

Dear Mr. Murley:

In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License No.

CPPR-106, -107, we transmit the following:

Attachment I - Response to Appendix A Also enclosed is an affidavit relating to the response.

Should you have any questions concerning these items, we would be pleased to discuss them with you.

Sincerely, ldfC,4~

JMC/mmk Attachments Copy to: Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D. C. 20555 S. K. Chaudhary, US NRC Resident Inspector 8307120508 830706 PDR ADOCK 05000352 G PDR

COMMONWEALT110F PENNSYLVANIA :

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COUNTY OF PilILADELPilIA  :

JOIIN S. KEMPER, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Limerick Generating Station Units 1 and 2; that he has read the foregoing Response to Inspection Report No. 50-352/83-05 and 50-353/83-02 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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ATTACHMENT I RESPONSE TO APPENDIX A Violation A -

10CFR50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and shall be ac-complished in accordance with these instructions. Also, it requires that the instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished.

Project Electrical Layout Drawing E-1406, Sections 2.3.c, d, e, f; 2.9; and 5.9 establish requirements for se)aration in raceways; Section 4.3.d establishes requirements for conduit ) ends.

Project Quality Control Instruction E-2, General Instruction No.10 states:

" Raceway separation verification is performed as part of the activities of PQCI E-2.0".

Project QCIE 2.0, Section 3.9 a, further requires that installed cable tray locations be verified for conformance to electrical layout drawings and meet horizontal and vertical location within tolerance. And, Section 2.7 requires the verification,of conduit bends.

Contrary to the above, on April 8,1983, the following violations were identified:

1. The separation requirements for electrical raceway (cable trays) were not verified in accordance with PQCI E-2.0, Section 3.9.a.

2. Project Quality Control Instruction PQCI E-2.0 did not include appro-priate inspection methods to verify quantitative acceptance criteria for conduit bends.

Response to Violation A The Notice of Violation relative to raceway separation references Project Quality Control Instruction 8031-E-2.0 and indicates that General Instruct-ion 10 states " Raceway separation verification is performed as part of the i activities of PQCI E-2.0". The report fails to indicate that the sentence immediately following the above states that " Additional separation veriff-cations are also performed in conjunction with the installation of raceway barriers and seals in accordance with PQCI E-3.0". It is now, and has always been the intent to verify final separation requirements which are met by the installation of barriers and seals when spatial separation is i not provided and that this inspection be performed and documented in '

I 1/2 50-352/83-05 50-353/83-02 1

Response to Violation A - Continued accordance with the requirements of Project Quality Control ' Instruction E-3.0.

However, in order to preclude further confusion relative to this subject, Project Quality Control Instruction E-2.0 has been revised to more clearly in-

, dicate that the separation inspections performed and documented in association with these instructions, are preliminary and that the final inspection activi-ties for separation shall be performed under PQCI 8031-E-3.0. The requirements for the installation of these barriers and seals are defined in Drawing 8031-E-1406.

With regard to the excessive benda in conduit, the Project Design Document (Drawing E-1406) has been revised by Design Change Notice 189 to state that the Field need only perform a visual inspection to assure that the bend criteria is met. The reason for the inspection of bonds is to minimize the amount of conduit rework during and just prior to cable pulling. An additional inspection of raceways is performed pst prior to cable pulling and all safety related cables are pulled under a 100% QC Inspection Program.

Consequently, a visual conduit bend inspection is all that was intended by the Project Design Document (Dwg. E-1h06) and this is now clearly defined.

Violation B 10CFR50, Appendix B, Criterion III requires that " Design Control measures shall

, provide for verifying or checking the adequacy of design....".

Section 10.1.4.2.4 of M-830 states the minimum separation between redundant in-strument sensing lines shall be at least 18 inches in air. As an alternative, a suitable steel or concrete barrier shall be used.

Contrary to the above, on April 8,1983, Drawing FJ-44-18, Revision 1, was issued, following engineering review and approval, containing incorrect separation criteria based on redlined Drawing FJ-44-18, Revision 0. The requirement for a suitable steel or concrete barrier was not evident in either drawing revision.

Response to Violation B Drawing FJ-44-18 was revised to include a steel barrier in compliance with Section

, 10.0 of M-830. The steel barrier has been installed between the redundant instru-ment sensing lines and Quality Control's inspection has found the barrier to be acceptable.

A final Civil Inspection of barriers and supports per PQCI 8031/I-1.10 had not taken place at the time of the NRC inspection. Only the tubing and instrument locations were inspected prior to the NRC inspection.

A review of drawings of other lines running to similar racks for similar condit-ions was conducted to ensure that minimum separation has been maintained. No other violations were noted during the review.

To prevent recurrence, the appropriate personnel were re-trained in separation requirements.

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50-352/83-05 l 50-353/80-02 l

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